Case Summary (G.R. No. 68357)
Background of the Case
On May 12, 2009, the DPWH filed a complaint for expropriation of three properties to address traffic issues in Taguig City. Respondents did not dispute the DPWH's right to expropriate but challenged the basis for the valuation of their lands. The Regional Trial Court (RTC) subsequently issued an Order of Expropriation on June 1, 2011. The Heirs of Isabel D. Lacsina asserted that their property's true market value was P6,000.00 per sq. m., considerably higher than the government's offered rate. Similarly, Cabever Realty Corporation argued for a much higher compensation based on commercial value, and St. Ignatius of Loyola School claimed its property was misclassified in terms of valuation.
Initial RTC Proceedings
A board of commissioners was appointed to determine just compensation in line with Rule 67 of the Rules of Court. The board recommended a fair market value of P10,000.00 per sq. m., along with consequential damages for Cabever and SILS for their remaining properties. The RTC, in its ruling, found the properties' valuation appropriate at P15,000.00 per sq. m. given their commercial use but denied consequential damages, stating that benefits derived from the expropriation outweighed damages.
Court of Appeals Decision
Upon appeal by the Republic, the Court of Appeals (CA) partially modified the RTC's decision. It affirmed the compensation for the expropriated properties at P10,000.00 per sq. m. and awarded consequential damages for unaffected portions of the properties at P5,000.00 per sq. m. Additionally, the CA imposed legal interest on the amounts due, ruling that it would accrue from the date of the filing of the expropriation complaint.
Supreme Court Ruling
The Republic challenged the CA's decision, arguing that the CA overstepped its jurisdiction by awarding consequential damages, which were not appealed by Cabever and SILS. The Supreme Court ruled in favor of the Republic, reiterating that a party who does not appeal a ruling cannot seek additional relief not granted in the original ruling. The Court emphasized that the awarding of conseque
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Case Overview
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner, Republic of the Philippines, represented by the Department of Public Works and Highways (DPWH-NCR), challenges the Decision dated October 18, 2018, and the Resolution dated March 21, 2019, of the Court of Appeals (CA).
- The CA affirmed the Decision dated February 18, 2015, of the Regional Trial Court (RTC), with modifications regarding just compensation and consequential damages awarded to the respondents.
Antecedents
- On May 12, 2009, the Republic filed a complaint for the expropriation of properties in Ususan, Taguig City, necessary for the completion of the Taguig Diversion Road.
- The properties involved were owned by three parties: Heirs of Isabel D. Lacsina, Cabever Realty Corporation (Cabever), and St. Ignatius of Loyola School (SILS).
- The initial Order of Expropriation was issued by the RTC on June 1, 2011, because respondents did not contest the right to expropriate but objected to the provisional valuation.
Respondents' Claims
- The heirs of Isabel D. Lacsina claimed their property’s market value was P6,000.00 per sq. m.
- Cabever argued for a higher valuation of P19,000.00 to P20,000.00 per sq. m., citing o